June 23, 2012
Dear Mr. Snow,
I am writing to express deep concern about California APA’s opposition
to reforming minimum parking requirements through AB 904. I have studied
parking regulations as part of my research for over a decade, half of which
time I was in California. It is without question that minimum parking
requirements are an egregious failure of planning, and the California APA’s
position seems to suggest that, despite decades of evidence to the contrary,
they know precisely how much parking should be supplied. The California APA’s
position is troubling, to say the least, and actually reinforces the circular
logic that got our cities into such trouble in the first place.
Minimum parking requirements increase the cost of housing,
increase the amount of land needed for development, and represent the single
largest subsidy to drivers. I will not dwell on these effects as the California
APA’s letter of opposition suggests that you are aware of the need for reform. Parking
reform should be at the top of any planner’s priorities for building better
cities. I do want to challenge some of your reasons for opposing AB 904, and show
why your concerns are unfounded.
In the basic issues section and in the specific concerns
section you are worried that the proposed reduction in required parking
minimums is not based on data. To quote your letter:

“Page
4, S. 65200 (a). It is not apparent how these parking minimums were
determined. They appear to be based on no specific data. Of
chief concern is the requirement for one parking space per thousand square feet
of any non-residential project regardless of use. Given that most
jurisdictions use 3-5 parking spaces per 1000 square feet for uses that require
the most parking, such as grocery stores, stadiums, park and ride lots, and
medical offices, this assumes that up to 75% of those using the project would
be using transit. That is a huge leap of faith and one likely to
detrimentally impact projects surrounding these facilities.”

This quote suggests that existing parking requirements are
based on something other than a huge leap of faith. They aren’t. No one knows
the right number of parking spaces, and no one knows how many parking spaces
are already built. Just because most jurisdictions require 3-5 spaces per 1,000
square feet does not mean they are correct. As a telling example of how
supposed “correct” parking requirements have performed, consider that the
amount of required parking built in the United States allows researchers to
estimate retail sales by looking at images of parking lots taken from outer
space. Remote Sensing Metrics, a company that specializes in counting the
number of cars parked in commercial and retail lots using satellite images,
correctly predicted that the 2011 holiday shopping season was going to be a
success because 39 percent of parking spaces were occupied at shopping malls.
We live in a world where 60 percent of parking spaces are vacant during good
times. I do not see how this indicates that cities know how to set parking
requirements. It does suggest that we build too many spaces. I agree that the
proposed minima in AB 904 seem a bit convenient, but so are existing
requirements. However, the proposed changes aim toward planning for people,
building better places, and achieving a broad set of planning goals. By
maintaining the status quo, the existing parking requirements make it easier
and cheaper to drive.

Another concern expressed is the definition of
transit-intensive areas, and you suggest that only areas with existing transit
service should be included. California is heavily investing in new transit
systems, and these systems take a long time to plan and build. Reducing
required parking now will make these areas better for transit when the transit
arrives. Requiring lots of parking in areas where transit will be built will
reduce the utility of the investment. We should build transit in areas that are
not dominated by automobiles because those are the types of areas where lots of
people will use transit! Lower required parking standards strengthen the
relationship between transit and land use.

Reforming parking policy is difficult, but also presents
opportunities for building a new regulatory framework that supports good
planning and flexibility for accommodating future needs and uses. Maintaining
the status quo hampers California’s ability to pursue creative policies that
are more equitable and economically viable and that promote vibrant
communities. I hope you will reconsider the APA California position.

Regards,

David King
Assistant Professor of Urban Planning
Graduate School of Architecture, Planning and Preservation
Columbia University

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About Me

David King is an Assistant Professor of Urban Planning.His research explores the impact of local
transportation planning on the built environment, public finance, social equity
and accessibility.As part of this
research he has written about the phenomenon of cruising for parking and used
spatial regression techniques to analyze travel behavior.He also studies how public policy influences
the adoption of new technologies to address congestion, energy and
environmental concerns.These issues are
the focus of Professor King’s teaching through his courses covering planning
techniques and methods, transportation and land use planning and transport
policy.